JRC supports the actions of the Commission for Communications Regulation (ComReg) for the proposed release of the radio spectrum noted and in particular the recommendation to assign 2 x 3 MHz of the band on a service specific basis to enable ‘Smart Grid’ activities in Ireland.
JRC encourages ComReg to adopt an open approach to the operating mode that can be used and in so doing permit both TDD and FDD to be deployed in the band and in so doing allow the entity that wins the spectrum to deploy it in whichever mode best serves their operational requirements.
The roll-out obligations proposed for the Part A lot require further consideration as they appear to be reflective of a typical mobile network roll-out where coverage drives revenue. The drivers behind the deployment of Smart Grid capability will be to establish enhanced asset utilisation, minimise customer outages, allow distributed generation to be connected quicker and increase availability.

JRC welcomes the emphasis on Communications Systems Capability as a ‘Key Enabler’ for the ‘Future Worlds.’ It is worth noting that a key input on which operational telecommunications systems depend is radio spectrum. To this end and as part of the ‘Future Worlds’ analysis we encourage ENA and Government to explore the Operational Telecommunications (OT) needs of the Industry and in so doing seek to understand how to best serve these needs through access to both fixed and wireless networks.
There is likely to be a tension between the Economic, Commercial and Financial case. Perhaps the Financial Case could be considered sub-ordinate to the Economic and Commercial cases, since it is likely that Funding issues will be addressed for those Future Worlds that satisfy both the Economic and Commercial criteria.

The JRC requests that the UK 26 GHz position be revised to align with the RSPG opinion (RSPG18-005 FINAL).
M2M and IoT appear to have become generic terms for most types of data transmission systems. The term Resilient Machine to Machine (RM2M) is becoming increasingly used to distinguish when an M2M system includes the necessary enhanced resilience.
JRC is concerned that, without sufficient restrictions, non-GSO systems operating within the 460 to 470 MHz band could cause harmful interference to the UK's electricity and gas grid monitoring and control systems.
JRC proposes the introduction of 'Utility Operations' as an ITU defined service in the same way as Public Safety and Disaster Relief (PPDR) and Programme Making and Special Events (PMSE) are identified as distinct services requiring special recognition.

It is important that ComReg does not overlook the importance of spectrum access for uses other than mobile data access. To this end we are encouraged by the initiative to enable access to the spectrum in the range 410-415.5 & 420-425.5 MHz which has the potential to support ‘Smart Grid’ developments in Ireland and be critical to helping the Irish Government deliver upon key environmental targets agreed with the International Community.

JRC supports the actions of the Commission for Communications Regulation (ComReg) for the proposed release of the radio spectrum noted and the establishment of a combined award of the bands identified to ensure that complementary bands are made available at the same time.
JRC supports ComReg’s proposal to exclude the following frequencies from the multi-band award process;
• 700 MHz Duplex Gap & Guard Band;
• 1.4 GHz Band, both Centre and Extension Bands; and
• 26 GHz Band.
The potential characteristics of use of these bands are different to those considered relevant to the multi-band award and therefore should be treated separately.

The four principles proposed in the consultation appear wise and well founded. However, there appear to be a number of significant assumptions in the consultation without the evidential basis to support the position being adopted. These include:
• The assumption that mobile phone networks will provide service during power cuts.
• The one hour minimum power backup duration seems sensible given the Ofgem data that 67% of power outages are restored within 1 hour.
• The assertion that most calls to the emergency services would occur shortly after the initial power outages has no evidential basis.
• Paragraph 3.10 describes a situation where some 'households have a history of long-duration power outages'. It is incumbent on the electricity network provider to remedy known situations.
• The increasing use of fempto cells to provide domestic mobile coverage, back-hauled on broadband, will not work if a power cut is not addressed.